Rat Bait Ban Must Be Reversed

Wednesday 13th Feb 2013

The National Gamekeepers' Organisation (NGO) has said that a 'devastating' ban on the use of certain rat baits away from buildings must be reversed.

Restrictions on the use of all defenacoum and bromadialone-based products were imposed arbitrarily by the Health and Safety Executive last week without warning or announcement, despite the fact that the HSE was in the middle of an ongoing review about their future.

As a result, rat baits based on these 'second generation' chemicals will now be labelled for use only 'in and around buildings', preventing thousands of gamekeepers and pest controllers from deploying them in the wider countryside.

In a letter sent today to Defra Minister, Lord de Mauley, the NGO Chairman, Lindsay Waddell, said the compounds were vital to proper rat control in the countryside and that the HSE had 'jumped the gun' on its own consultation, imposing 'sweeping restrictions which would have a devastating impact'. He wrote:

"Rat control in open areas will be seriously compromised, with significant adverse impacts on the food and farming industries, the environment, wildlife and not least public health."

But it is worse even than that. In response to the NGO's protests, the HSE has now said that if its own review shows over the next few months that it has made the wrong decision, it will reverse it. The pest control industry, gamekeeping and farming are thus being thrown into turmoil and significant additional costs, causing massive confusion among product users, and for no good reason.

The HSE's actions were prompted by a longstanding concern that residues of the second generation products are often found in non-target species such as foxes, badgers and buzzards. This is true, because they sometimes consume treated rats, but the levels at which residues occur in these predators are sub-lethal. No-one has ever shown a welfare effect, let alone any link between the correct outdoor use of rat bait and the populations of non-target species, most of which are thriving.

The NGO concluded its letter to the Minister by asking him, "To investigate immediately how this shambles has been allowed to happen and to get the restrictions lifted pending proper completion of the HSE's review."

The NGO believes the way forward with these products is to reduce residues in wildlife through best practice, linked to operator training.

In the meantime gamekeepers and others following the precise on-label instructions on any product they already have will not be breaking the law.

The full text of the NGO's letter to the Minister reads as follows:

Dear Lord de Mauley,

RAT CONTROL CRISIS FOLLOWING HSE RESTRICTIONS

I am writing to you as the Minister responsible for chemical regulationand the work in this regard of the Health and Safety Executive (HSE).

We learned last week that the HSE had arbitrarily imposed restrictions onthe rodenticide, difenacoum, and that they are imminently going to dothe same for the bromadialone-based rat baits too. The details arecomplex but essentially, these 'second generation' products, which havebeen available for many years, are the ones that reliably kill rats,whereas the first generation compounds, such as warfarin, are much lesseffective these days owing to resistance.

The two chemicals named above were, until last week, the only secondgeneration compounds allowed for use in open areas as opposed to 'inand around buildings'.

They were deployed, we estimate, by threequarters of all gamekeepers and also by farmers and many hundreds ofpest control operators doing rat control in places like public parks,recreation grounds and rubbish dumps. The Chartered Institute forEnvironmental Health calculates that hundreds of thousands of rattreatments were involved. The products were the method of choice formost outdoor rat control.

All this must now stop because the HSE has changed the labelling instructions such that rat baits based on these two compounds can henceforth only be used 'in and around buildings'. In theory there is a phase out period lasting up to 18 months, during which 'old-labelled' product can still be used up in open areas but in practice the 'old-labelled' product will run out long before that, meaning that operators controlling rats in open areas will have no choice but to use ineffective first generation products or rely on traps, shooting and gas, none of which is a direct substitute for the second generation rodenticides. Rat control in open areas will thus be seriously compromised, with significant adverse impacts on the food and farming industries, the environment, wildlife and not least public health.

The HSE's actions were prompted by a longstanding concern that residues of the second generation products are often found in non-target species such as foxes, badgers and buzzards. This is true, because they sometimes consume treated rats, but the levels at which residues occur in these predators are sub-lethal. No-one has ever shown a welfare effect, let alone any link between the correct outdoor use of rat bait and the populations of non-target species, most of which are thriving.

What makes the HSE's actions completely unacceptable is that they are currently in the process of a proper Risk Management Review, specifically looking at the whole issue to find a workable way forward. There was a public consultation late last year and the HSE is still in the process of considering the responses, many of which - including our own - emphasised just how important the outdoor use of the second generation products was. There had been talk from the HSE up until last week of further consultations and of seeking the views of Ministers and then suddenly we learnt the products had been already restricted. There was no public announcement or information campaign whatsoever.

The HSE has thus jumped the gun on its own consultation and imposed sweeping restrictions which will have a devastating impact on rat control. In response to our protests, they now blithely tell us they will reverse their decision if their review concludes, in the next few months, that they have made a mistake. In the meantime, the pest control industry, gamekeeping and farming are being thrown into turmoil and significant additional costs. There will be massive confusion among product users for no proven benefit whatever. The HSE's restrictions apply throughout Great Britain.

I would therefore urge you, please, to investigate immediately how this shambles has been allowed to happen and to get the restrictions lifted pending proper completion of the HSE's review. We believe the way forward with these products is to reduce residues in wildlife through best practice, linked to operator training.

The matter could not be more urgent and is of great importance to very many professionals trying to keep on top of the UK's serious rat problem. I await your early response and actions to correct the situation.